Internal Revenue Service (IRS) Rulemaking
In addition to representing IRS tax whistleblowers like world’s largest IRS Tax Fraud whistleblower Bradley Birkenfeld
Kohn, Kohn & Colapinto’s partners have been in the forefront of seeking to enhance the legal protections for tax whistleblowers, and have filed rule-making petitions to the IRS to strengthen the tax whistleblower program.

Kohn, Kohn & Colapinto’s experienced tax fraud whistleblower attorneys filed the following briefs in support of IRS whistleblower rights:
- November 29, 2012: KKC filed an extensive brief on behalf of the National Whistleblower Center before the IRS strongly urging it to reward whistleblowers who exposed criminal tax frauds.
- February 19, 2013: KKC authored an 84-page comment, on behalf of the NWC, on the proposed IRS whistleblower rules, strongly opposing the criminal disqualification.
- April 16, 2013: One of our tax whistleblower attorneys testified at the IRS rule-making hearing opposing the criminal reward disqualification.
- June 5, 2014: We provided the Secretary of Treasury with and exhaustive 55-page scholarly article co-authored by KKC Partner Stephen M. Kohn and Dean Zerbe, Partner in Zerbe, Miller, Fingeret, Frank & Jadav, that explained in detail the legal basis as to why the criminal reward disqualification was illegal and should not be approved by the IRS. A copy of this article, published in Tax Notes, is linked here.
- Finally, Dean Zerbe and Steve Kohn, through their respective law firms, agreed to work with the legal team representing anonymous whistleblowers 21276/77-13W, in order to ensure that the IRS program properly implemented the whistleblower reward law, and criminal fines and penalties were included in any reward calculation.